Instances when secular courts can intervene in church disputes (Supreme Court ruling in Fonacier vs. Court of Appeals and Isabelo De los Reyes, Jr., 1955)

Summary: [1] Case title: “Santiago A. Fonacier, petitioner, vs. Court of Appeals and Isabelo De los Reyes, Jr., respondents” G.R. No. L-5917, January 28, 1955 [2] Supreme Court ruling: (A) While the civil courts will ordinarily leave ecclesiastical matters to church authorities, they may however intervene when it is shown that they have acted outside the scope of their authority or in a manner contrary to their organic law and rules. (B) Civil courts have jurisdiction to revise decisions on ecclesiastical matters where it is necessary for settling the question of civil and property rights, or when property rights are affected. (C) Civil courts can intervene if a member is expelled without due process and a property right is involved. [3] Plain English explanation: Secular courts can intervene in church disputes (a) if the pastor, board, or congregation, acted contrary to the church constitution or rules; or (b) when the dispute affects personal or property rights; or (c) if a member is expelled without due process and a property right is involved. [4] Related post: “Doctrine of Church Autonomy: secular courts and church disputes” Note: Claro M. Recto was the lawyer for the respondents. He later on became a senator known for his nationalism; the famous avenue in Manila is named after him. Ferdinand E. Marcos acted as the Supreme Court’s amicus curiae (“friend of the court”).

Facts of the case:

[1] The Iglesia Filipina Independiente (IFI), represented by its Supreme Bishop Gerardo M. Bayaca, filed a case with the Court of First Instance (CFI) of Manila against Bishop Santiago A. Fonacier. The IFI sought to require Bishop Fonacier to render an accounting of his administration of all the temporal properties in his possession belonging to the church and to recover the properties from him. The IFI claimed that Fonacier had ceased to be its Supreme Bishop.

Bishop Isabelo de los Reyes, Jr., having been elected as Supreme Bishop after the filing of the original complaint, was later made a co-plaintiff in a supplementary complaint.

[2] Fonacier claimed in his defense that:

(a) he has not been properly removed as Supreme Bishop;

(b) his legal successor was Juan Jamias who had been elected in accordance with the church constitution ;

(c) Bishop De los Reyes, Jr. formally joined the Protestant Episcopal Church of America and for this reason ceased to be a member of the Iglesia Filipina Independiente;

(d) Bishops De los Reyes and Bayaca having abandoned the faith, fundamental doctrines and practices of the Iglesia Filipina Independiente, ceased to be members and consequently, have no personality in filing the complaint.

[3] On May 17, 1950, the court rendered judgment declaring Mons. Isabelo de los Reyes, Jr. as the sole and legitimate Supreme Bishop of the Iglesia Filipina Independiente, and ordering Mons. Fonacier to render an accounting of his administration of the properties and funds of the church.

[4] The Court of Appeals affirmed the decision of the CFI. Fonacier then filed a petition for review with the Supreme Court.

Some issues raised by Fonacier and the Supreme Court ruling

[1] Issue: The Court of Appeals erred “in holding that the ouster of Bishops Manuel Aguilar, Alejandro Remollino, Isabelo de los Reyes Jr., Gerardo Bayaca, Juan Quijano and Pablo Tablante decreed by the Supreme Council and the petitioner as Obispo Maximo was illegal.”

Ruling: The civil courts have jurisdiction to review the action regarding the ouster.

(A) “Where a decision of an ecclesiastical court plainly violates the law it professes to administer, or is in conflict with the laws of the land, it will not be followed by the civil courts.”

(B) “Expulsion of a member without notice or an opportunity to be heard is not conclusive upon the civil courts when a property right is involved.”

“Since it is claimed that the ouster was made by an unauthorized person, or in a manner contrary to the constitution of the church, and that the ousted bishops were not given notice of the charges against them nor were they afforded an opportunity to be heard, the civil courts, have jurisdiction to review the action regarding the ouster.”

[2] Issue: The Court of Appeals erred in holding that the abandonment of the constitution, restatement of articles of religion and abandonment of faith or abjuration alleged by petitioner are unquestionably ecclesiastical matters which are outside the province of the civil courts.

Ruling: “The amendments of the constitution, restatement of articles of religion, and abandonment of faith or abjuration alleged by appellant, having to do with faith, practice, doctrine, form of worship, ecclesiastical law, custom and rule of a church having reference to the power of excluding from the church those allegedly unworthy of membership, are unquestionably ecclesiastical matters which are outside the province of the civil courts.” (45 Am. Jur., 748-752, 755.)